Financial conflicts of interest

Significant financial interests that must be disclosed

Employees must disclose the following significant financial interests of (1) the employee and (2) persons to whom the employee has a commitment in a private capacity. Only financial interests that could reasonably be considered to be related to an employee’s University responsibilities need to be disclosed. If the external entity could benefit from your decisions or actions as a University employee, it is related to your University responsibilities. Even if you don't actually do anything at the University that benefits the outside entity, if the potential for benefit exists, you should disclose your interest.

• Compensation from and/or equity in publicly traded companies: Disclose if the aggregate value of compensation and equity interests received from a U.S. or foreign publicly traded company exceeded $5,000 in the 12 months preceding the disclosure; or if it is anticipated that the aggregate value of compensation and/or equity interests in such a company will exceed $5,000 in the 12 months following the disclosure.
• Equity interest in non-publicly traded entities: Disclose any equity interest in a U.S., or foreign non-publicly traded company, regardless of value, that was received or held within the 12 months preceding the disclosure or anticipated in the 12 months following the disclosure.
• Compensation from non-publicly traded companies, non-profit institutions, and governmental organizations: Disclose if the aggregate value of compensation received from a U.S. or foreign non-publicly traded company, non-profit institution, or governmental organization exceeded $5,000 in the 12 months preceding the disclosure; or if it is anticipated that the aggregate value of such compensation will exceed $5,000 in the 12 months following the disclosure.
• Intellectual property rights and interests: (a) royalty income from traditional scholarly works (e.g., books, book chapters, articles, similar copyrightable works) – disclose if the aggregate income from an external entity exceeded $5,000 in the 12 months preceding the disclosure; (b) royalty income and intellectual property rights not related to traditional scholarly works – disclose any level of income, as well as any licensing and/or other agreements for commercialization of innovations, whether or not any royalties or payments have been received.

Compensation includes anything of value received from an outside entity in any form, including, but not limited to: salary, consulting fees, speaker fees, honoraria, paid authorship, paid or reimbursed travel, loans, stocks, bonds, stock options, rights to patent or royalty payments, financial support for students and laboratory personnel, laboratory or office space, and high-value materials not freely available.

Financial interests that do not need to be disclosed

• Salary, royalties, or other compensation paid by the University to a person who is a current employee.
• Equity interests in or income from investment vehicles (e.g., mutual funds and retirement accounts) when the employee does not directly control the investment decisions made by these vehicles.
• Income from seminars, lectures, or teaching engagements sponsored by U.S. federal, state, or local government; a U.S. Institution of Higher Education (as defined by 20 U.S.C. 1001 (a)); an academic teaching hospital, a medical center, or a research institute that is affiliated with a U.S. Institution of Higher Education. Such income from foreign institutions must be disclosed.
• Income from service on advisory committees or review panels for a U.S. federal, state, or local government, a U.S. Institution of Higher Education (as defined by 20 U.S.C. 100 (a)); an academic teaching hospital, a medical center, or a research institute that is affiliated with a U.S. Institution of Higher Education. Such income from foreign institutions must be disclosed.